Executive Summary
This documents the second five-year review of the Compass Industries Site in Tulse County, Oklahoma,
which was scheduled to be completed in 2000, but was delayed by weather until January 2001. The remedy
for the site consists of an approximately 50-acre RCRA-type Cap over the landfill. Post completion
activities consist of obtaining and analyzing samples of the water from seeps located adjacent to the
site and from the surface of the cap; inspecting the cap for deterioration and settlement; and,
maintaining the site as a secured area.
The remedy, including the post closure Operations and Maintenance, is protective of human health and
the environment. The remedy is functioning as designed. The cap is generally in good condition, with
noticeable minor repairs having beer made in the past. Settlement has been minimal. All analyses of
the surface water have shown no contaminants above the remedy threshold. The fence has kept the site
generally secure with only infrequent trespassing noted.
As there is waste left in place, another five-year review is scheduled for FY 2006. It is recommended
that this site be considered for partial or whole deletion from the National Priority List.
TABLE OF CONTENTS
Executive Summary
Five-Year Review Summary Form
Acronyms
I. Introduction ......................................................... 1
II. Chronology of Remediation Activities ................................ 2
III. Background..... .................................................... 2
A. Site Location and Description ................................. 2
B. History ....................................................... 4
C. Investigations ................................................ 4
D. Land Use Restrictions ......................................... 5
IV. Remedial Actions .................................................... 5
A. Record of Decision (ROD)....................................... 5
B. Remedial Activities ........................................... 6
C. Operations and Maintenance Activities ......................... 7
D. Results from the First 5- Year Review.......................... 7
V. Five-Year Review Process ............................................. 8
VI. Five-Year Review Findings ........................................... 8
A. Community Involvement ......................................... 8
B. Review of Existing Data ....................................... 8
Water Sampling Results ........................................ 8
Settlement .................................................... 9
Vent Sampling ................................................. 9
C. Site Inspection .............................................. 11
Inspection of the Cap ........................................ 11
Security ..................................................... 11
VII. Assessment ........................................................ 11
VIII. Deficiencies ..................................................... 12
IX. Recommendations and Follow- up Actions ............................. 13
X. Statement of Protectiveness ......................................... 14
XI. Next Five- Year Review ............................................. 14
XII. Other Comments .................................................... 14
Attachments
Attachment 1 ........................................... Documents Reviewed
Attachment 2 .................................................. Photographs
Attachment 3 ...................... Water Sample Data - O&M Surface Samples
Attachment 4 ...................................... Cap Vent Emissions Data
Attachment 5 .......................................... Cap Settlement Data
Acronyms
BDL Below Detection Limit
BOD Biochemical Oxygen Demand
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
COD Carbon Oxygen Demand U. S. Army
COE Corps of Engineers, Tulsa District
EPA U. S. Environmental Protection Agency
HDPA High Density Polyethylene
HRS Hazard Ranking Score
IAG Interagency agreement
mg/l milligrams per liter (ppm)
NCP National Contingency Plan
NPL National Priorities List
OSDH Oklahoma State Department of Health
OSWER Office of Solid Waste and Emergency Response
O&M Operations and Maintenance
PCB Polychlorinated Biphenyls
ppb parts per billion parts
ppm per million
PRP Potentially Responsible Party
RCRA Resource Conservation and Recovery Act
RI/FS Remedial Investigation/Feasibility Study
ROD Record of Decision
TOC Total Organic Carbon
TSS Total Suspended Solids
ug/l micrograms per liter (ppb)
I. Introduction
The Compass Industries Superfund Site is a former landfill which has been capped, with none of the
contaminants removed. Remedial Action at the site began in 1991) and was essentially complete that
same year. The site is currently under Operations & Maintenance (O&M) and is restricted from public or
private use.
The purpose of this report is to document the second five-year review and to comply with the
requirements of Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as
amended, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), and the Office of
Solid Waste and Emergency Response (OWSER) Guidance 9355.7-03B-P/EPA 540 R-98-050, dated October 1999.
This review has been performed pursuant to Section 121(c) of CERCLA which states:
"If the President selects a remedial action that results in any hazardous substances,
pollutants, or contaminants remaining at the site, the President shall review such remedial
action no less often than each 5 years after the initiation of such remedial action to assure
that human health and the environment are being protected by the remedial action being
implemented."
Subpart E of the NCP {40 CFR 300.430(f)(4)(ii)} delegates this responsibility to the lead agency, in
this case the U. S. Environmental Protection Agency (EPA).
This report is provided by the U. S. Army Corps of Engineers, Tulsa District (COE), under EPA
Interagency Agreement No. DW96934255-01-06 for Hazardous Waste Enforcement Support at the Compass
Industries, OK site. The EPA has utilized the Tulsa District as its sole oversight agent throughout
the Remedial Design, Remedial Act on, and Operations and Maintenance (O&M) of the site. Under this
IAG, the Tulsa District, provided full-time on-site monitoring during the remedial action, monitored
the O& M contractor and performed Quality Assurance testing. The Tulsa District has assisted the EPA,
alerting EPA to O&M activities, providing technical assistance, and enfarcing its requirements.
This report summarizes the data obtained under this agreement and provides the tecinical
recommendations for continued activity at the site. This information has been summarized on the Five-
Year Review Summary Form.
II. Chronology of Remediation Activities
A brief chronology of the activities concerning the Compass Industries site and involving the EPA is
provided in Table 1.
III. Background
A. Site Location and Description
The Compass Industries Superfund Site is located in western Tulsa County, Oklahoma near the community
of Berryhill. The remediation area occupies approximately 50 acres in the northeastern portion of the
125-acre site. This area is bounded on the east by the Chandler Park baseball diamonds, by the bluffs
on the northern side just above Avery Drive and the Arkansas River, and the road through the site to
the south.
The topography of the site has been modified by quarrying, landfill, and remediation activities. The
road to the south of the remediation area forms a drainage divide and most of the surface water from
Chandler Park flows into one of two draws located in the park area. Therefore, the majority of surface
runofffrom this site results from precipitation directly upon the site rather than run-on from other
areas. Run-off from the remediation area flows in a generally westerly direction to the western
portion of the site where the flow is intercepted by a draw of an unnamed tributary of the Arkansas
River.
John Mathes and Associates identified two aquifers under the Compass Site during the Remedial
Investigation. They consist of a perched aquifer and an unconfined aquifer and are depicted in an
East-West Cross-section provided in the Remedial Investigation Report. There is no known use for the
water contained in either of these two aquifers.
Subsurface water in the upper (perched) aquifer had consisted primarily of water resulting from
percolation of precipitation which fell directly upon the site and soaked into the loose fill
materials. Additional recharge is probably provided through cracks in the limestone (Hogshooter
Formation) adjacent to the site. The underlying shale (Coffeville Formation) forms the low
permeability basal boundary of this aquifer. Outcrops of these formations occur along the northern
bluffs, often associated with ground water seeps.
The unconfined aquifer is located 37 to 52 feet below the top of the Coffeyville shale in the Layton
Sandstone Formation. Some recharge of this aquifer is believed to be tr rough its overlying shale
formation, but, because of the low permeability of the shale, this recharge is believed to be a very
small amount. Discharge from this aquifer is again through small seeps in the bluffs on the northwest
side.
___________________________________________________________________________________________
Table 1
Chronology of Remediation Activities
Early 1983 Air Monitoring by EPA and OSDH after repeated complaints by local residents and the
media
Sept. 1983 Compass Industries Site proposed for the NPL
July 1984 EPA and OSDH enter Cooperative Agreement to undertake RI/FS
Sept. 1984 Site listed on NPL July 1987 Remedial Investigation Report Published
Aug. 1987 Endangerment Assessment
Sept. 1987 Record of Decision
Aug. 1988 Award of Remedial Design Contract
Mar. 1989 Unilateral Administrative Order issued by EPA against 7 PRPs
Apr. 1989 EPA approves Final Design
Jan. 1990 Remedial Action begins with construction of test fill
Oct. 1990 Remedial Action complete, except turfing
June 1991 Remedial Action complete
Aug. 1991 O&M Plan accepted by EPA
Oct. 1993 EPA notifies PRPs of intent to monitor vents and seeps adjacent to cap
Sept. 2000 First 5 Year report finalized
_________________________________________________________________________________________
B. History
The Compass Industries Superfund Site was originally operated as a quarry. Based upon aerial
photography, in 1938 the quarry already occupied approximately 44 acres or about 35% of the total 125
acres included in the site today. The Remedial Investigation report states that the limestone at this
site was being utilized as early as 1904 for cement-making and railroad ballast and that a crusher was
in operation by 1906. Quarrying operations continued into the early 1960s. Aerial photography from
1964 shows that quarrying operations had ceased and waste disposal activities had started.
Photographic evidence shows waste disposal and landfill activities continued at ths site into the
1980s. The only period during which landfill activities were permitted by the Oklahoma State
Department of Health was between 1972 and 1976. The permit allowed the site to be operated as a
municipal landfill, but did not allow the disposal of industrial wastes.
Very few records were maintained by the landfill operators concerning the disposal of wastes or cell
locations. However, records do show that the site accepted three categories of hazardous wastes:
solids, liquids, and sludges, which included acids, caustics, potentially toxic solvents, and
potentially carcinogenic materials. Aerial photographs indicate numerous wet areas and pools of
liquid. Sequential photographs show apparent overlapping and irregular filling of landfill cells,
making delineation of the cells very difficult.
During the 1970s fires began to appear at landfill. These fires continued until 1984. Often these
fires were the result of spontaneous combustion of the waste materials and burned underground for
extended periods of time. The smoke expelling from the ground during these fires was noticeably multi-colored
and produced odors which prompted citizens' complaints. Photographs depicting these conditions
were included in the first 5-Year Report.
As a result of these citizens' complaints, monitoring in the vicinity of the site was conducted by the
U. S. Environmental Protection Agency and the Oklahoma State Department of Health (OSDH). Based upon
this monitoring, the site was proposed for the Mational Priorities List (NPL) in September 1983 and
listed on the NPL in September 1984. The Hazard Ranking Score (HRS) for the site was 36.57, with the
air route of exposure receiving a significantly higher score than either the ground water or surface
water exposure routes.
C. Investigations
During the initial site investigation in November 1983 conducted by several EPA contractors, seven
monitoring wells (four shallow and three deep) were installed and a biological investigation was
conducted. The wells were sampled in January 1984 and June 1985. During 1983 and 1984, an aerial
photographic survey was conducted and approximately 28 borings were installed at the site to
extinguish underground fires. These investigations were followed by the Remedial Investigation which
was conducted in 1986.
The Remedial Investigation (RI) was conducted by the Oklahoma State Department of Health, with John
Mathes and Associates, Inc., as the State's construction contractors. During the RI, eleven additional
monitoring wells were installed. Five of these were deep monitoring wells, extending into the Layton
Sandstone Formation, while the remaining six were shallow wells for monitoring the perched water
table. Ground water samples obtained from the wells, seep water samples obtained from the perimeter
bluffs, and surface water samples from drainage ways around the perimeter of the landfill were
collected and analyzed. Samples were analyzed for inorganic and organic priority pollutants, Total
Organic Carbon (TOC), and barium, chloride, fluoride, and sulfate. Additionally samples from the
monitoring wells were analyzed for Carbon Oxygen Demand (COD).
Water analyses concentrations of benzene at three surface locations and one seep location varying
between 1.5 and 2.2 ug/l, exceeded the toxic substance goal concentration established by the Clean
Water Act Water Quality Criteria for drinking water.
Soil samples from the landfill surface, from trenches, and from sediment in drainage ways leaving the
site were obtained and analyzed. The waste had high concentrations of priority pollutant metals,
volatile organics, and base-neutral organics, but surface samples and sediment samples had much lower
concentrations of organic compounds.
Air sampling was conducted during subsurface explorations. This identified a significant concentration
of relatively low hazard nuisance gases, but only trace quant ties of toxic volatile organic vapors.
D. Land Use Restrictions
The EPA has had deed restrictions incorporated into the deeds for these sites. The EPA has required
that no activity occur which may damage the landfill cap.
IV. Remedial Actions
A. Record of Decision (ROD)
Based upon this Remedial Investigation, a Feasibility Study was performed. The preferred alternative
for addressing the contamination at Compass was to cap the site and provide on-site ground water
treatment. The EPA, after public comment, signed the ROD on September 29,1987. The salient features of
the ROD were:
1) construction of a Resource Conservation and Recovery Act (RCRA) cap over a graded site with
diversion of surface water and monitoring of air emissions;
2) treatment of the ground water, if deemed necessary from monitoring results, after construction of
the RCRA cap;
3) restricting site access by installing a fence and posting signs;
4) monitoring the site for 30 years to ensure no significant contamination migrates from the site;
and,
5) providing for additional Remedial Action if significant migration of contaminants occurs.
B. Remedial Activities
The contract for the design of the Remedial Action was awarded to Bechtel Environmental, Inc., in
August 1988 by the Oklahoma State Department of Health.
The primary objectives of the Remedial Action were:
1) to prevent direct contact between the contaminated site materials, including soil, leachate,
surface waters, and air emissions, and the human and animal population;
2) to prevent the infiltration of precipitation into the waste; and,
3) to divert surface run- on and promote natural drainage of precipitation from the landfill.
The Remedial Action began in January 1990 with the construction of the first test fill. After site
mobilization, the contractor installed the leachate collection system as the first item of site work.
Then the contractor began grubbing of the heavy vegetation. Following the grubbing, the waste was
reshaped by excavating the material from the areas that were high and filling in the low areas. All
materials were compacted to reduce settlement of the cap.
The waste at the perimeter was excavated until a bottom width of 36 inches of clean material was
obtained and no waste remained on the exterior slope. Prior to backfilling the trench and covering the
waste with impermeable clay material, a gas transmission geotextile was placed directly over the
graded waste surface to intercept gases,
The clay material was placed in the trench and over the waste and compacted. This was overlain by a
geosynthetic liner system, consisting of an impermeable membrane (30 mil nominal thickness HDPE) and a
subsurface drainage system. A sandy soil was placed over the drainage system and covered with topsoil
and native grasses.
Construction was considered essentially complete in October 1990. Remaining work at that time
consisted of repairing damage which occurred during the first winter and pi anting native grasses.
Both of these items were accomplished in the Spring of 1991.
C. Operation and Maintenance Activities
The O&M Plan includes the following requirements.
1) Water leaving the surface of the landfill and water seeping from the bluffs north of the site
(above Avery Drive) shall be sampled quarterly.
2) Settlement monuments shall be surveyed at least annually to determine settlement/swell within the
landfill.
3) Inspect the landfill surface semiannually. Repair cracks, fill voids, and reseed as required.
4) Maintain security of the site, including fencing and signage.
Requirements added during the O&M period included sampling the air vents for the presence of organic
gases and sampling a seep adjacent to the cap.
The PRPs contracted with Flint Environmental Services (a division of Flint Engineering & Construction
Co.) to operate the site. Flint was responsible for completing the tasks assigned in the O& M Plan. In
1994, Flint Engineering & Construction Co. divested itself of Flint Environmental Services. Mr. J.
Scott Stelle, R.E.M., who had been the Project Manager, has operated the site since that time. Plans
were underway at the time of the Five-Year Review for the City of Sand Springs to takes control of the
Operations and Maintenance activities.
D. Results from the First 5-Year Review
The results are the first 5-Year Review are as follow.
1) The remedy of a RCRA type cap over the landfill was found to be operating as designed. Water
samples from the shallow aquifer exposed in seeps adjacent to the cap and surface water were below
action levels set forth in the Operating and Maintenance Plan. The cap was in good condition, with
minor repairs having been made. Settlement of the cap had been minimal.
2) No major deficiencies were noted. It was recommended that the grass be mowed every four years,
woody vegetation be removed, and periodic checks be made of the cap to repair soil erosion and
prevent holes from burrowing animals.
V. Five-Year Review Process
The Compass Industries Five-Year Review was led Mr. Shawn Ghose, Remedial Project Manager for the
site. Other persons involved in the review included Mr. Richard Smith, COE Project Manager, Mr. Jeff
London, COE Program Manager, and Mr. Scott Stello, O& M Contractor.
The Five-Year Review consisted of reviewing the data (contaminants of concern in the EPA approved O&M
plan) gathered from the O& M sampling events against the established criteria, interviewing local
emergency responders, and an inspection of the site.
VI. Five-Year Review Findings
A. Community Involvement
The Compass Industries Superfund Site is located in a relatively remote area of western Tulsa County.
The nearest residences are located in an area called Berryhill, an unincorporated community having a
high school and a fire station. In an effort to determine any community problems, the EPA
representative stopped at the Berryhill fire station and met with representatives of the fire
department and the Tulsa County Sheriffs Office in November 2000. Some persons present had vivid
memories of the site prior to its being remediated and the problems during that time, indicating they
were aware of the site. During the discussion, however, these persons, who would be emergency
responders to problems at the site, indicated that they were unaware of any community concern
regarding the site and that since the remediation work at the site was completed, there had been no
activity at the site which had attracted their attention.
B. Review of Existing Data
Water Sampling Results
Sampling of the seeps on the bluffs began in February 1992, except for the seep adjacent to the cap
which was first sampled in August and September 1991. An additional seep had been located adjacent to
the landfill along the northern side during the summer of 1991. No seeps have been sampled since 1995
because the seeps have stopped flowing and efforts to locate them have been unsuccessful. This
indicates that the cap is working as designed and is preventing infiltration of water into the
landfill.
Water collecting on the surface of the cap after a significant rain is also collected quarterly, as
practical. Samples have consistently been below the Monitoring Concentration Levels established in the
O&M Plan. Table 2 provides maximum allowable concentrations for the contaminants of concern and the
respective maximum concentration from actual samples. Tables of the surface water sampling results are
provided in Attachment 3.
Settlement
Data from the first 5-year report indicated that movement at individual monuments have been as great
as 0.16 ft. (~2 in.) between annual surveys. The survey required during the 10th year had not been
performed at the time of the inspection. Settlement amounts of the magnitude previously identified are
normal for this type of construction and do not pose any problem to the integrity of the cap.
Vent Sampling
The PRPs have sampled the vents monthly since receiving direction from the EPA in October 1993.
Consistently, several vents have indicated the presence of organic vapors. This indicates that the
waste is continuing to off gas and that the venting system is working. The organic vapor
concentrations appear to be lowering and are higher during warm weather, indicating a reduction in the
degradation of the waste. The organic vapors are probably methane gas from the biodegradation of the
waste materials and will not constitute a hazard in the open atmosphere at these levels. The results
of the vent sampling are provided in Attachment 4.
C. Site Inspection
Inspection of the Cap
The vegetative cover is well established. The site is covered with native grasses except in the main
swale where Bermuda grass was planted to control the erosion. The bermuda grass has continued to
thrive in spite of no maintenance. The native grasses are beginning to naturally seed this area and
mix with the bermuda grasses. The vegetative cover is holding the soil in place, as there are no new
erosion sites and the prior erosion sites have been repaired. There are some bare spots, which have
been reseeded. Also, some slopes have woody vegetation which must be removed prior to its damaging the
liner.
The drainage system appears to be working property. Wet areas at the west end commonly remain after
most other areas have dried. Initially, it was suspected that this may be seepage from the landfill,
but monitoring over several years has shown cyclic wetting and drying. The wet areas dry after a
prolonged dry spell and do not reappear until after a wet period has occurred with suitable time for
the water to infiltrate the soil and pass through the drainage system. Also, the riprap at the west
end remains in generally good condition. The riprap at the end of the drainage swale has been
repaired, but some additional rock is required.
Security
There is no evidence of continued or long-term use of the site, although evidence that unauthorized
persons have been on the site have been noted. The evidence includes theft of warning signs and broken
gates and fence. Other vandalism or damage to the cap have not occurred.
VII. Assessment
Question A: Is the remedy functioning as intended by the decision documents?
• Construction of a RCRA cap over a graded site with diversion of surface water: The RCRA cap was
determined to be in proper working order during the inspection. The flow of water through the
seeps has effectively stopped, indicating that surface water is not percolating into the waste.
• Treatment of the ground water, if necessary: No contaminants above the thresholds established
in the O&M plan have been identified. Therefore, there is no need for a treatment system as the
cap is providing adequate protectiveness of the ground water.
• Restricting site access by installing a fence and installing warning signs: The fence and
warning signs have been installed. As the site is located several hundred yards from any
populated area and is used for recreational purposes by children and young adults for
activities such as dirt bike riding, some trespassing does occur. However, the vandalism has
been limited to stealing signs and breaking through the fence to ride. This vandalism does not
endanger the remedy or the health of the vandals.
• Monitoring the site for 30 years to ensure no significant contamination migrates from the site:
The data reviewed in conjunction with this five- year review indicate that the site is being
monitored on a regular basis and that there is no migration of contaminants from the site.
Question B: Are the assumptions used at the time of the remedy selection still valid?
• Changes in Standards: No change of the contaminants of concern or ARARs were identified during
this review, which would affect the remedy selection. The maximum contaminant levels were
established in the O& M Plan for this specific site.
• Changes in exposure pathways: No changes have been noted as there have been no changes in land
use around this site.
Question C; Has any other information come to light that could call into question the protectiveness
of the remedy?
No additional information has been identified that would call into question the protectiveness of the
remedy.
VIII. Deficiencies
No major deficiencies were noted during the Five-Year review, as the data were adequate and the site
inspection revealed no major deficiencies. Several minor and potential deficiencies were identified
during the inspection. These included:
a) Woody shrubs are clearly evident in an area along the northern slope where the cover is above the
natural ground and must be removed.
b) Riprap which was placed at the lower end of the swale during recent repairs did not completely
cover all of the geotextile. Additional rock needs to be placed here.
c) The settlement monuments which were scheduled to be surveyed during the 10th year will be surveyed
as soon as practical. Responsibility for O&M activities changing from Sun-Texaco to the City of
Sand Springs may delay completion of this activity.
d) As the area returns to native vegetation, woody plants with strong root systems may damage the
liner system; therefore, woody vegetation must be removed at least annually.
e) Continued mowing of the native grasses may result in a buildup of thatch; therefore if mowing
continues the site should be raked approximately every 4 years.
f) Burrowing animals including mice, rats, and snakes may also damage the liner system; therefore
periodic checks on the site should continue.
g) Erosion of the protective soil continues to be a concern and should be periodically inspected to
insure that the full 24- inches remain intact.
IX. Recommendations and Follow- up Actions
The first three deficiencies noted above require action on the part of the PRPs. Since the
responsibility for O&M activities is changing from Sun-Texaco to the City of Sand Springs, additional
time is being allowed for correction of these deficiencies.
Deficiency Scheduled Completion Actual Completion
Remove woody growth along northern slope June 2001 April 2001
Place additional riprap at end of drainage swale
at west end of cap
June 2001 April 2001
Survey settlement monuments June 2001 April 2001
The O&M contractor was reminded to be continually aware of the potential deficiencies identified and
to be vigilant about making the repairs. Under the requirements of the ROD, the PRPs are responsible
for monitoring and maintaining the site for a period of at least 30 years.
X. Statement of Protectiveness
Because the remedial action is expected to be protective, the remedy for the site is expected to be
protective of human health and the environment. Based upon the site inspections, the sampling results,
and the survey results, the remedial actions are performing well. The RCRA Cap system has been well
maintained and now is performing its function with minimal maintenance and movement. The ground water
leaving the site, when present, has been substantially below the monitoring concentrations, never
having exceeded 10% of any level. The site appurtenant structures, including the fencing, the signs,
and the vent pipes, are in sound condition with no signs of physical deterioration. All contaminants
of concern appear to be fully controlled by the RCRA Cap.
XI. Next Five-Year Review
The next Five- Year Review will be conducted during FY 2006. The results of this review support the
view that the scope of the next Five- Year Review should be limited to an inspection of the RCRA Cap
System and the appurtenant structures to ascertain that they are not being damaged by animals or the
elements and that vandalism of the site is controlled.
XII. Other Comments
The processes to delete this site from the NPL should be investigated as the remedy has proved to be
protective of human health and the environment. The site may be separated into two distinct areas: 1)
the capped portion of the site where waste remains; and, 2) the remaining portion of the site which
does not have waste. The Latter area may be deleted without restriction. The capped area should be
evaluated to determine if it meets the requirements of 40 CFR 300.425(e)(1). Contingent upon meeting
those requirements, the deletion should include institutional controls to maintain the integrity of
the cap.
Attachment 1
Documents Reviewed
Agency for Toxic Substances and Disease Registry, (U. S. Department of Health and Human Services),
Compass Industries (Avery Drive), Tulsa, Tulsa County, OK, Site Review and Update, December 16,1993
(Revised).
Bechtel Environmental, Inc., Final Design Report for Remedial Action, Compass Industries Superfund
Site, March, 1989 (Prepared for the Oklahoma State Department of Health, EPA Cooperative Agreement No.
V-006459-01-0).
Bechtel Environmental, Inc., Specifications and Bidding Documents for Remedial Action, Compass
Industries Superfund Site, March, 1989 (Prepared for the Oklahoma State Department of Health, Contains
Scope of Work, Quality Assurance Project Plan and Site Safety Plan).
Bechtel Environmental, Inc., Remedial Action Report, for the Compass Industries Superfund Site,
January, 1991.
Bechtel Environmental, Inc., Post Closure Operations and Maintenance Plan for the Compass Industries
Superfund Site, August, 1991 (Revised by letters dated February 21,1992 and October 6, 1993).
Camrud, M. J., Compass Industries Superfund Site, Unpublished Paper, July 17, 1994.
Environmental Protection Agency, Compass Industries Landfill, Tulsa County, OK, Record of Decision,
September 29, 1987.
Environmental Protection Agency, Compass Industries Site, Tulsa County, OK, First Amended
Administrative Order, May 31, 1989.
Environmental Protection Agency, Close Out Report, Compass Industries Landfill Superfund Site, Tulsa
County, OK, June 30, 1992.
Environmental Protection Agency, Five-Year Review Report, Compass Industries Landfill Superfund Site,
Tulsa County, OK, September 2000.
Flint [Environmental Services (A Division of Flint Engineering & Construction Co.), 1992 Annual
Monitoring Report, Compass Industries Site, January 29, 1993.
Flint [Environmental Services (A Division of Flint Engineering & Construction Co.), 1993 Annual
Monitoring Report, Compass Industries Site, January 18, 1994.
Lockheed Engineering and Management Services Company, Inc., Aerial Photographic Analysis of Compass
Industries Landfill, Tulsa, OK, August, 1984.
John Mathes & Associates, Inc., Remedial Investigation Report, Compass Industries Land Fill, Superfund
Site, Tulsa County, Volume 1. July 13,1987. (Prepared for the Oklahoma State Department of Health).
John Mathes & Associates, Inc., Feasibility Study Report, Compass Industries Landfill, Superfund Site,
Tulsa County, July 13,1987. (Prepared for the Oklahoma State Department of Health).
John Mathes & Associates, Inc., Endangerment Assessment, Compass Industries Lancfill, Superfund Site,
Tulsa County, August 10,1987. (Prepared for the Oklahoma State Department of Health).
J. Scott Stelle, R. E. M., 1994 Annual Monitoring Report, Compass Industries Site, December 30, 1994.
U. S. Army Corp of Engineers, Tulsa District, Quality Assurance Final Report, Corrpass Industries
Superfund Site, Volumes I, II, and III, January, 1991.
Attachment 2
Photographs
Attachment 3
Water Sample Data
O&M Surface Samples
Attachment 4
Cap Vent Emissions Data
Attachment 5
Cap Settlement Data

Click tabs to swap between content that is broken into logical sections.

Executive Summary
This documents the second five-year review of the Compass Industries Site in Tulse County, Oklahoma,
which was scheduled to be completed in 2000, but was delayed by weather until January 2001. The remedy
for the site consists of an approximately 50-acre RCRA-type Cap over the landfill. Post completion
activities consist of obtaining and analyzing samples of the water from seeps located adjacent to the
site and from the surface of the cap; inspecting the cap for deterioration and settlement; and,
maintaining the site as a secured area.
The remedy, including the post closure Operations and Maintenance, is protective of human health and
the environment. The remedy is functioning as designed. The cap is generally in good condition, with
noticeable minor repairs having beer made in the past. Settlement has been minimal. All analyses of
the surface water have shown no contaminants above the remedy threshold. The fence has kept the site
generally secure with only infrequent trespassing noted.
As there is waste left in place, another five-year review is scheduled for FY 2006. It is recommended
that this site be considered for partial or whole deletion from the National Priority List.
TABLE OF CONTENTS
Executive Summary
Five-Year Review Summary Form
Acronyms
I. Introduction ......................................................... 1
II. Chronology of Remediation Activities ................................ 2
III. Background..... .................................................... 2
A. Site Location and Description ................................. 2
B. History ....................................................... 4
C. Investigations ................................................ 4
D. Land Use Restrictions ......................................... 5
IV. Remedial Actions .................................................... 5
A. Record of Decision (ROD)....................................... 5
B. Remedial Activities ........................................... 6
C. Operations and Maintenance Activities ......................... 7
D. Results from the First 5- Year Review.......................... 7
V. Five-Year Review Process ............................................. 8
VI. Five-Year Review Findings ........................................... 8
A. Community Involvement ......................................... 8
B. Review of Existing Data ....................................... 8
Water Sampling Results ........................................ 8
Settlement .................................................... 9
Vent Sampling ................................................. 9
C. Site Inspection .............................................. 11
Inspection of the Cap ........................................ 11
Security ..................................................... 11
VII. Assessment ........................................................ 11
VIII. Deficiencies ..................................................... 12
IX. Recommendations and Follow- up Actions ............................. 13
X. Statement of Protectiveness ......................................... 14
XI. Next Five- Year Review ............................................. 14
XII. Other Comments .................................................... 14
Attachments
Attachment 1 ........................................... Documents Reviewed
Attachment 2 .................................................. Photographs
Attachment 3 ...................... Water Sample Data - O&M Surface Samples
Attachment 4 ...................................... Cap Vent Emissions Data
Attachment 5 .......................................... Cap Settlement Data
Acronyms
BDL Below Detection Limit
BOD Biochemical Oxygen Demand
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
COD Carbon Oxygen Demand U. S. Army
COE Corps of Engineers, Tulsa District
EPA U. S. Environmental Protection Agency
HDPA High Density Polyethylene
HRS Hazard Ranking Score
IAG Interagency agreement
mg/l milligrams per liter (ppm)
NCP National Contingency Plan
NPL National Priorities List
OSDH Oklahoma State Department of Health
OSWER Office of Solid Waste and Emergency Response
O&M Operations and Maintenance
PCB Polychlorinated Biphenyls
ppb parts per billion parts
ppm per million
PRP Potentially Responsible Party
RCRA Resource Conservation and Recovery Act
RI/FS Remedial Investigation/Feasibility Study
ROD Record of Decision
TOC Total Organic Carbon
TSS Total Suspended Solids
ug/l micrograms per liter (ppb)
I. Introduction
The Compass Industries Superfund Site is a former landfill which has been capped, with none of the
contaminants removed. Remedial Action at the site began in 1991) and was essentially complete that
same year. The site is currently under Operations & Maintenance (O&M) and is restricted from public or
private use.
The purpose of this report is to document the second five-year review and to comply with the
requirements of Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as
amended, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), and the Office of
Solid Waste and Emergency Response (OWSER) Guidance 9355.7-03B-P/EPA 540 R-98-050, dated October 1999.
This review has been performed pursuant to Section 121(c) of CERCLA which states:
"If the President selects a remedial action that results in any hazardous substances,
pollutants, or contaminants remaining at the site, the President shall review such remedial
action no less often than each 5 years after the initiation of such remedial action to assure
that human health and the environment are being protected by the remedial action being
implemented."
Subpart E of the NCP {40 CFR 300.430(f)(4)(ii)} delegates this responsibility to the lead agency, in
this case the U. S. Environmental Protection Agency (EPA).
This report is provided by the U. S. Army Corps of Engineers, Tulsa District (COE), under EPA
Interagency Agreement No. DW96934255-01-06 for Hazardous Waste Enforcement Support at the Compass
Industries, OK site. The EPA has utilized the Tulsa District as its sole oversight agent throughout
the Remedial Design, Remedial Act on, and Operations and Maintenance (O&M) of the site. Under this
IAG, the Tulsa District, provided full-time on-site monitoring during the remedial action, monitored
the O& M contractor and performed Quality Assurance testing. The Tulsa District has assisted the EPA,
alerting EPA to O&M activities, providing technical assistance, and enfarcing its requirements.
This report summarizes the data obtained under this agreement and provides the tecinical
recommendations for continued activity at the site. This information has been summarized on the Five-
Year Review Summary Form.
II. Chronology of Remediation Activities
A brief chronology of the activities concerning the Compass Industries site and involving the EPA is
provided in Table 1.
III. Background
A. Site Location and Description
The Compass Industries Superfund Site is located in western Tulsa County, Oklahoma near the community
of Berryhill. The remediation area occupies approximately 50 acres in the northeastern portion of the
125-acre site. This area is bounded on the east by the Chandler Park baseball diamonds, by the bluffs
on the northern side just above Avery Drive and the Arkansas River, and the road through the site to
the south.
The topography of the site has been modified by quarrying, landfill, and remediation activities. The
road to the south of the remediation area forms a drainage divide and most of the surface water from
Chandler Park flows into one of two draws located in the park area. Therefore, the majority of surface
runofffrom this site results from precipitation directly upon the site rather than run-on from other
areas. Run-off from the remediation area flows in a generally westerly direction to the western
portion of the site where the flow is intercepted by a draw of an unnamed tributary of the Arkansas
River.
John Mathes and Associates identified two aquifers under the Compass Site during the Remedial
Investigation. They consist of a perched aquifer and an unconfined aquifer and are depicted in an
East-West Cross-section provided in the Remedial Investigation Report. There is no known use for the
water contained in either of these two aquifers.
Subsurface water in the upper (perched) aquifer had consisted primarily of water resulting from
percolation of precipitation which fell directly upon the site and soaked into the loose fill
materials. Additional recharge is probably provided through cracks in the limestone (Hogshooter
Formation) adjacent to the site. The underlying shale (Coffeville Formation) forms the low
permeability basal boundary of this aquifer. Outcrops of these formations occur along the northern
bluffs, often associated with ground water seeps.
The unconfined aquifer is located 37 to 52 feet below the top of the Coffeyville shale in the Layton
Sandstone Formation. Some recharge of this aquifer is believed to be tr rough its overlying shale
formation, but, because of the low permeability of the shale, this recharge is believed to be a very
small amount. Discharge from this aquifer is again through small seeps in the bluffs on the northwest
side.
___________________________________________________________________________________________
Table 1
Chronology of Remediation Activities
Early 1983 Air Monitoring by EPA and OSDH after repeated complaints by local residents and the
media
Sept. 1983 Compass Industries Site proposed for the NPL
July 1984 EPA and OSDH enter Cooperative Agreement to undertake RI/FS
Sept. 1984 Site listed on NPL July 1987 Remedial Investigation Report Published
Aug. 1987 Endangerment Assessment
Sept. 1987 Record of Decision
Aug. 1988 Award of Remedial Design Contract
Mar. 1989 Unilateral Administrative Order issued by EPA against 7 PRPs
Apr. 1989 EPA approves Final Design
Jan. 1990 Remedial Action begins with construction of test fill
Oct. 1990 Remedial Action complete, except turfing
June 1991 Remedial Action complete
Aug. 1991 O&M Plan accepted by EPA
Oct. 1993 EPA notifies PRPs of intent to monitor vents and seeps adjacent to cap
Sept. 2000 First 5 Year report finalized
_________________________________________________________________________________________
B. History
The Compass Industries Superfund Site was originally operated as a quarry. Based upon aerial
photography, in 1938 the quarry already occupied approximately 44 acres or about 35% of the total 125
acres included in the site today. The Remedial Investigation report states that the limestone at this
site was being utilized as early as 1904 for cement-making and railroad ballast and that a crusher was
in operation by 1906. Quarrying operations continued into the early 1960s. Aerial photography from
1964 shows that quarrying operations had ceased and waste disposal activities had started.
Photographic evidence shows waste disposal and landfill activities continued at ths site into the
1980s. The only period during which landfill activities were permitted by the Oklahoma State
Department of Health was between 1972 and 1976. The permit allowed the site to be operated as a
municipal landfill, but did not allow the disposal of industrial wastes.
Very few records were maintained by the landfill operators concerning the disposal of wastes or cell
locations. However, records do show that the site accepted three categories of hazardous wastes:
solids, liquids, and sludges, which included acids, caustics, potentially toxic solvents, and
potentially carcinogenic materials. Aerial photographs indicate numerous wet areas and pools of
liquid. Sequential photographs show apparent overlapping and irregular filling of landfill cells,
making delineation of the cells very difficult.
During the 1970s fires began to appear at landfill. These fires continued until 1984. Often these
fires were the result of spontaneous combustion of the waste materials and burned underground for
extended periods of time. The smoke expelling from the ground during these fires was noticeably multi-colored
and produced odors which prompted citizens' complaints. Photographs depicting these conditions
were included in the first 5-Year Report.
As a result of these citizens' complaints, monitoring in the vicinity of the site was conducted by the
U. S. Environmental Protection Agency and the Oklahoma State Department of Health (OSDH). Based upon
this monitoring, the site was proposed for the Mational Priorities List (NPL) in September 1983 and
listed on the NPL in September 1984. The Hazard Ranking Score (HRS) for the site was 36.57, with the
air route of exposure receiving a significantly higher score than either the ground water or surface
water exposure routes.
C. Investigations
During the initial site investigation in November 1983 conducted by several EPA contractors, seven
monitoring wells (four shallow and three deep) were installed and a biological investigation was
conducted. The wells were sampled in January 1984 and June 1985. During 1983 and 1984, an aerial
photographic survey was conducted and approximately 28 borings were installed at the site to
extinguish underground fires. These investigations were followed by the Remedial Investigation which
was conducted in 1986.
The Remedial Investigation (RI) was conducted by the Oklahoma State Department of Health, with John
Mathes and Associates, Inc., as the State's construction contractors. During the RI, eleven additional
monitoring wells were installed. Five of these were deep monitoring wells, extending into the Layton
Sandstone Formation, while the remaining six were shallow wells for monitoring the perched water
table. Ground water samples obtained from the wells, seep water samples obtained from the perimeter
bluffs, and surface water samples from drainage ways around the perimeter of the landfill were
collected and analyzed. Samples were analyzed for inorganic and organic priority pollutants, Total
Organic Carbon (TOC), and barium, chloride, fluoride, and sulfate. Additionally samples from the
monitoring wells were analyzed for Carbon Oxygen Demand (COD).
Water analyses concentrations of benzene at three surface locations and one seep location varying
between 1.5 and 2.2 ug/l, exceeded the toxic substance goal concentration established by the Clean
Water Act Water Quality Criteria for drinking water.
Soil samples from the landfill surface, from trenches, and from sediment in drainage ways leaving the
site were obtained and analyzed. The waste had high concentrations of priority pollutant metals,
volatile organics, and base-neutral organics, but surface samples and sediment samples had much lower
concentrations of organic compounds.
Air sampling was conducted during subsurface explorations. This identified a significant concentration
of relatively low hazard nuisance gases, but only trace quant ties of toxic volatile organic vapors.
D. Land Use Restrictions
The EPA has had deed restrictions incorporated into the deeds for these sites. The EPA has required
that no activity occur which may damage the landfill cap.
IV. Remedial Actions
A. Record of Decision (ROD)
Based upon this Remedial Investigation, a Feasibility Study was performed. The preferred alternative
for addressing the contamination at Compass was to cap the site and provide on-site ground water
treatment. The EPA, after public comment, signed the ROD on September 29,1987. The salient features of
the ROD were:
1) construction of a Resource Conservation and Recovery Act (RCRA) cap over a graded site with
diversion of surface water and monitoring of air emissions;
2) treatment of the ground water, if deemed necessary from monitoring results, after construction of
the RCRA cap;
3) restricting site access by installing a fence and posting signs;
4) monitoring the site for 30 years to ensure no significant contamination migrates from the site;
and,
5) providing for additional Remedial Action if significant migration of contaminants occurs.
B. Remedial Activities
The contract for the design of the Remedial Action was awarded to Bechtel Environmental, Inc., in
August 1988 by the Oklahoma State Department of Health.
The primary objectives of the Remedial Action were:
1) to prevent direct contact between the contaminated site materials, including soil, leachate,
surface waters, and air emissions, and the human and animal population;
2) to prevent the infiltration of precipitation into the waste; and,
3) to divert surface run- on and promote natural drainage of precipitation from the landfill.
The Remedial Action began in January 1990 with the construction of the first test fill. After site
mobilization, the contractor installed the leachate collection system as the first item of site work.
Then the contractor began grubbing of the heavy vegetation. Following the grubbing, the waste was
reshaped by excavating the material from the areas that were high and filling in the low areas. All
materials were compacted to reduce settlement of the cap.
The waste at the perimeter was excavated until a bottom width of 36 inches of clean material was
obtained and no waste remained on the exterior slope. Prior to backfilling the trench and covering the
waste with impermeable clay material, a gas transmission geotextile was placed directly over the
graded waste surface to intercept gases,
The clay material was placed in the trench and over the waste and compacted. This was overlain by a
geosynthetic liner system, consisting of an impermeable membrane (30 mil nominal thickness HDPE) and a
subsurface drainage system. A sandy soil was placed over the drainage system and covered with topsoil
and native grasses.
Construction was considered essentially complete in October 1990. Remaining work at that time
consisted of repairing damage which occurred during the first winter and pi anting native grasses.
Both of these items were accomplished in the Spring of 1991.
C. Operation and Maintenance Activities
The O&M Plan includes the following requirements.
1) Water leaving the surface of the landfill and water seeping from the bluffs north of the site
(above Avery Drive) shall be sampled quarterly.
2) Settlement monuments shall be surveyed at least annually to determine settlement/swell within the
landfill.
3) Inspect the landfill surface semiannually. Repair cracks, fill voids, and reseed as required.
4) Maintain security of the site, including fencing and signage.
Requirements added during the O&M period included sampling the air vents for the presence of organic
gases and sampling a seep adjacent to the cap.
The PRPs contracted with Flint Environmental Services (a division of Flint Engineering & Construction
Co.) to operate the site. Flint was responsible for completing the tasks assigned in the O& M Plan. In
1994, Flint Engineering & Construction Co. divested itself of Flint Environmental Services. Mr. J.
Scott Stelle, R.E.M., who had been the Project Manager, has operated the site since that time. Plans
were underway at the time of the Five-Year Review for the City of Sand Springs to takes control of the
Operations and Maintenance activities.
D. Results from the First 5-Year Review
The results are the first 5-Year Review are as follow.
1) The remedy of a RCRA type cap over the landfill was found to be operating as designed. Water
samples from the shallow aquifer exposed in seeps adjacent to the cap and surface water were below
action levels set forth in the Operating and Maintenance Plan. The cap was in good condition, with
minor repairs having been made. Settlement of the cap had been minimal.
2) No major deficiencies were noted. It was recommended that the grass be mowed every four years,
woody vegetation be removed, and periodic checks be made of the cap to repair soil erosion and
prevent holes from burrowing animals.
V. Five-Year Review Process
The Compass Industries Five-Year Review was led Mr. Shawn Ghose, Remedial Project Manager for the
site. Other persons involved in the review included Mr. Richard Smith, COE Project Manager, Mr. Jeff
London, COE Program Manager, and Mr. Scott Stello, O& M Contractor.
The Five-Year Review consisted of reviewing the data (contaminants of concern in the EPA approved O&M
plan) gathered from the O& M sampling events against the established criteria, interviewing local
emergency responders, and an inspection of the site.
VI. Five-Year Review Findings
A. Community Involvement
The Compass Industries Superfund Site is located in a relatively remote area of western Tulsa County.
The nearest residences are located in an area called Berryhill, an unincorporated community having a
high school and a fire station. In an effort to determine any community problems, the EPA
representative stopped at the Berryhill fire station and met with representatives of the fire
department and the Tulsa County Sheriffs Office in November 2000. Some persons present had vivid
memories of the site prior to its being remediated and the problems during that time, indicating they
were aware of the site. During the discussion, however, these persons, who would be emergency
responders to problems at the site, indicated that they were unaware of any community concern
regarding the site and that since the remediation work at the site was completed, there had been no
activity at the site which had attracted their attention.
B. Review of Existing Data
Water Sampling Results
Sampling of the seeps on the bluffs began in February 1992, except for the seep adjacent to the cap
which was first sampled in August and September 1991. An additional seep had been located adjacent to
the landfill along the northern side during the summer of 1991. No seeps have been sampled since 1995
because the seeps have stopped flowing and efforts to locate them have been unsuccessful. This
indicates that the cap is working as designed and is preventing infiltration of water into the
landfill.
Water collecting on the surface of the cap after a significant rain is also collected quarterly, as
practical. Samples have consistently been below the Monitoring Concentration Levels established in the
O&M Plan. Table 2 provides maximum allowable concentrations for the contaminants of concern and the
respective maximum concentration from actual samples. Tables of the surface water sampling results are
provided in Attachment 3.
Settlement
Data from the first 5-year report indicated that movement at individual monuments have been as great
as 0.16 ft. (~2 in.) between annual surveys. The survey required during the 10th year had not been
performed at the time of the inspection. Settlement amounts of the magnitude previously identified are
normal for this type of construction and do not pose any problem to the integrity of the cap.
Vent Sampling
The PRPs have sampled the vents monthly since receiving direction from the EPA in October 1993.
Consistently, several vents have indicated the presence of organic vapors. This indicates that the
waste is continuing to off gas and that the venting system is working. The organic vapor
concentrations appear to be lowering and are higher during warm weather, indicating a reduction in the
degradation of the waste. The organic vapors are probably methane gas from the biodegradation of the
waste materials and will not constitute a hazard in the open atmosphere at these levels. The results
of the vent sampling are provided in Attachment 4.
C. Site Inspection
Inspection of the Cap
The vegetative cover is well established. The site is covered with native grasses except in the main
swale where Bermuda grass was planted to control the erosion. The bermuda grass has continued to
thrive in spite of no maintenance. The native grasses are beginning to naturally seed this area and
mix with the bermuda grasses. The vegetative cover is holding the soil in place, as there are no new
erosion sites and the prior erosion sites have been repaired. There are some bare spots, which have
been reseeded. Also, some slopes have woody vegetation which must be removed prior to its damaging the
liner.
The drainage system appears to be working property. Wet areas at the west end commonly remain after
most other areas have dried. Initially, it was suspected that this may be seepage from the landfill,
but monitoring over several years has shown cyclic wetting and drying. The wet areas dry after a
prolonged dry spell and do not reappear until after a wet period has occurred with suitable time for
the water to infiltrate the soil and pass through the drainage system. Also, the riprap at the west
end remains in generally good condition. The riprap at the end of the drainage swale has been
repaired, but some additional rock is required.
Security
There is no evidence of continued or long-term use of the site, although evidence that unauthorized
persons have been on the site have been noted. The evidence includes theft of warning signs and broken
gates and fence. Other vandalism or damage to the cap have not occurred.
VII. Assessment
Question A: Is the remedy functioning as intended by the decision documents?
• Construction of a RCRA cap over a graded site with diversion of surface water: The RCRA cap was
determined to be in proper working order during the inspection. The flow of water through the
seeps has effectively stopped, indicating that surface water is not percolating into the waste.
• Treatment of the ground water, if necessary: No contaminants above the thresholds established
in the O&M plan have been identified. Therefore, there is no need for a treatment system as the
cap is providing adequate protectiveness of the ground water.
• Restricting site access by installing a fence and installing warning signs: The fence and
warning signs have been installed. As the site is located several hundred yards from any
populated area and is used for recreational purposes by children and young adults for
activities such as dirt bike riding, some trespassing does occur. However, the vandalism has
been limited to stealing signs and breaking through the fence to ride. This vandalism does not
endanger the remedy or the health of the vandals.
• Monitoring the site for 30 years to ensure no significant contamination migrates from the site:
The data reviewed in conjunction with this five- year review indicate that the site is being
monitored on a regular basis and that there is no migration of contaminants from the site.
Question B: Are the assumptions used at the time of the remedy selection still valid?
• Changes in Standards: No change of the contaminants of concern or ARARs were identified during
this review, which would affect the remedy selection. The maximum contaminant levels were
established in the O& M Plan for this specific site.
• Changes in exposure pathways: No changes have been noted as there have been no changes in land
use around this site.
Question C; Has any other information come to light that could call into question the protectiveness
of the remedy?
No additional information has been identified that would call into question the protectiveness of the
remedy.
VIII. Deficiencies
No major deficiencies were noted during the Five-Year review, as the data were adequate and the site
inspection revealed no major deficiencies. Several minor and potential deficiencies were identified
during the inspection. These included:
a) Woody shrubs are clearly evident in an area along the northern slope where the cover is above the
natural ground and must be removed.
b) Riprap which was placed at the lower end of the swale during recent repairs did not completely
cover all of the geotextile. Additional rock needs to be placed here.
c) The settlement monuments which were scheduled to be surveyed during the 10th year will be surveyed
as soon as practical. Responsibility for O&M activities changing from Sun-Texaco to the City of
Sand Springs may delay completion of this activity.
d) As the area returns to native vegetation, woody plants with strong root systems may damage the
liner system; therefore, woody vegetation must be removed at least annually.
e) Continued mowing of the native grasses may result in a buildup of thatch; therefore if mowing
continues the site should be raked approximately every 4 years.
f) Burrowing animals including mice, rats, and snakes may also damage the liner system; therefore
periodic checks on the site should continue.
g) Erosion of the protective soil continues to be a concern and should be periodically inspected to
insure that the full 24- inches remain intact.
IX. Recommendations and Follow- up Actions
The first three deficiencies noted above require action on the part of the PRPs. Since the
responsibility for O&M activities is changing from Sun-Texaco to the City of Sand Springs, additional
time is being allowed for correction of these deficiencies.
Deficiency Scheduled Completion Actual Completion
Remove woody growth along northern slope June 2001 April 2001
Place additional riprap at end of drainage swale
at west end of cap
June 2001 April 2001
Survey settlement monuments June 2001 April 2001
The O&M contractor was reminded to be continually aware of the potential deficiencies identified and
to be vigilant about making the repairs. Under the requirements of the ROD, the PRPs are responsible
for monitoring and maintaining the site for a period of at least 30 years.
X. Statement of Protectiveness
Because the remedial action is expected to be protective, the remedy for the site is expected to be
protective of human health and the environment. Based upon the site inspections, the sampling results,
and the survey results, the remedial actions are performing well. The RCRA Cap system has been well
maintained and now is performing its function with minimal maintenance and movement. The ground water
leaving the site, when present, has been substantially below the monitoring concentrations, never
having exceeded 10% of any level. The site appurtenant structures, including the fencing, the signs,
and the vent pipes, are in sound condition with no signs of physical deterioration. All contaminants
of concern appear to be fully controlled by the RCRA Cap.
XI. Next Five-Year Review
The next Five- Year Review will be conducted during FY 2006. The results of this review support the
view that the scope of the next Five- Year Review should be limited to an inspection of the RCRA Cap
System and the appurtenant structures to ascertain that they are not being damaged by animals or the
elements and that vandalism of the site is controlled.
XII. Other Comments
The processes to delete this site from the NPL should be investigated as the remedy has proved to be
protective of human health and the environment. The site may be separated into two distinct areas: 1)
the capped portion of the site where waste remains; and, 2) the remaining portion of the site which
does not have waste. The Latter area may be deleted without restriction. The capped area should be
evaluated to determine if it meets the requirements of 40 CFR 300.425(e)(1). Contingent upon meeting
those requirements, the deletion should include institutional controls to maintain the integrity of
the cap.
Attachment 1
Documents Reviewed
Agency for Toxic Substances and Disease Registry, (U. S. Department of Health and Human Services),
Compass Industries (Avery Drive), Tulsa, Tulsa County, OK, Site Review and Update, December 16,1993
(Revised).
Bechtel Environmental, Inc., Final Design Report for Remedial Action, Compass Industries Superfund
Site, March, 1989 (Prepared for the Oklahoma State Department of Health, EPA Cooperative Agreement No.
V-006459-01-0).
Bechtel Environmental, Inc., Specifications and Bidding Documents for Remedial Action, Compass
Industries Superfund Site, March, 1989 (Prepared for the Oklahoma State Department of Health, Contains
Scope of Work, Quality Assurance Project Plan and Site Safety Plan).
Bechtel Environmental, Inc., Remedial Action Report, for the Compass Industries Superfund Site,
January, 1991.
Bechtel Environmental, Inc., Post Closure Operations and Maintenance Plan for the Compass Industries
Superfund Site, August, 1991 (Revised by letters dated February 21,1992 and October 6, 1993).
Camrud, M. J., Compass Industries Superfund Site, Unpublished Paper, July 17, 1994.
Environmental Protection Agency, Compass Industries Landfill, Tulsa County, OK, Record of Decision,
September 29, 1987.
Environmental Protection Agency, Compass Industries Site, Tulsa County, OK, First Amended
Administrative Order, May 31, 1989.
Environmental Protection Agency, Close Out Report, Compass Industries Landfill Superfund Site, Tulsa
County, OK, June 30, 1992.
Environmental Protection Agency, Five-Year Review Report, Compass Industries Landfill Superfund Site,
Tulsa County, OK, September 2000.
Flint [Environmental Services (A Division of Flint Engineering & Construction Co.), 1992 Annual
Monitoring Report, Compass Industries Site, January 29, 1993.
Flint [Environmental Services (A Division of Flint Engineering & Construction Co.), 1993 Annual
Monitoring Report, Compass Industries Site, January 18, 1994.
Lockheed Engineering and Management Services Company, Inc., Aerial Photographic Analysis of Compass
Industries Landfill, Tulsa, OK, August, 1984.
John Mathes & Associates, Inc., Remedial Investigation Report, Compass Industries Land Fill, Superfund
Site, Tulsa County, Volume 1. July 13,1987. (Prepared for the Oklahoma State Department of Health).
John Mathes & Associates, Inc., Feasibility Study Report, Compass Industries Landfill, Superfund Site,
Tulsa County, July 13,1987. (Prepared for the Oklahoma State Department of Health).
John Mathes & Associates, Inc., Endangerment Assessment, Compass Industries Lancfill, Superfund Site,
Tulsa County, August 10,1987. (Prepared for the Oklahoma State Department of Health).
J. Scott Stelle, R. E. M., 1994 Annual Monitoring Report, Compass Industries Site, December 30, 1994.
U. S. Army Corp of Engineers, Tulsa District, Quality Assurance Final Report, Corrpass Industries
Superfund Site, Volumes I, II, and III, January, 1991.
Attachment 2
Photographs
Attachment 3
Water Sample Data
O&M Surface Samples
Attachment 4
Cap Vent Emissions Data
Attachment 5
Cap Settlement Data